Kathleen A. Carr - Page 7

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               Petitioner has substantiated the amounts in dispute.  The              
          issue for decision is whether these expenses are ordinary and               
          necessary.                                                                  
          Preliminary Matters                                                         
               In the stipulation of facts, respondent reserved objections            
          to several joint exhibits.  Specifically, respondent objected on            
          the basis of relevancy to Joint Exhibit 4-D, a subagent franchise           
          agreement; Joint Exhibit 5-E, a directory from the Conference of            
          Personal Managers; and Joint Exhibit 10-J, a breakdown of                   
          available jobs in the entertainment industry.  In addition,                 
          respondent objected on the basis of hearsay to Joint Exhibit 7-G,           
          excerpts from a book entitled "Managers', Entertainers', & Agents           
          Book"; Joint Exhibit 8-H, excerpts from a book entitled "How to             
          Manage Talent"; and Joint Exhibit 9-I, an excerpt entitled "But,            
          What Does a Personal Manager Do?" from the National Conference of           
          Personal Managers.                                                          
               Proceedings in this Court are conducted in accordance with             
          the Federal Rules of Evidence.  Sec. 7453; Rule 143.  Relevant              
          evidence means evidence having any tendency to make the existence           
          of any fact that is of consequence to the determination of the              
          action more or less probable than it would be without the                   

          5(...continued)                                                             
          for repairs and maintenance of $129.47 which was neither allowed            
          nor disallowed by the notice of deficiency and was not mentioned            
          in the stipulation of facts of stipulation of settled issues.               
          Thus, we will assume such amount is not in dispute.                         




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